Pricing, Costs and Fees Policy – BITX, S.L.

1. Purpose and scope

1.1 This Policy describes how BITX, S.L. ("BITX") determines the prices at which it exchanges crypto-assets for funds and funds for crypto-assets, the costs and fees that apply to that service, and the limits that BITX applies to the amounts exchanged. It is published in accordance with Articles 66(4) and 77 of Regulation (EU) 2023/1114 (MiCA).

1.2 BITX provides a single crypto-asset service: the exchange of crypto-assets for funds. In every transaction BITX acts as principal, buying from or selling to the Client on its own account. BITX does not operate a trading platform, does not execute orders on behalf of clients and does not act as the Client's agent or broker. The Terms and Conditions published on this website govern the service; this Policy forms part of the contractual documentation referred to in them.

1.3 This Policy applies to all Clients without distinction. Capitalised terms have the meaning given in the Terms and Conditions.

2. Commercial policy

2.1 BITX accepts as Clients natural persons of legal age with full legal capacity and legal entities validly incorporated, in each case once they have completed BITX's onboarding and due-diligence process and have been accepted in accordance with BITX's customer acceptance policy. Every Client must hold a bank account in its own name with a credit, payment or electronic-money institution; BITX does not accept cash or third-party payments.

2.2 BITX does not provide the service to persons located in, established in or resident of jurisdictions subject to sanctions or identified as high-risk for anti-money laundering purposes, unless expressly accepted following enhanced due diligence, nor to persons subject to sanctions or whose activity is excluded by BITX's customer acceptance policy. The eligibility conditions are set out in clause 3 of the Terms and Conditions.

2.3 The same price-formation method and the same conditions apply to all Clients. BITX does not use agents or third parties to acquire Clients.

3. How prices are formed

3.1 Every price communicated to a Client is the result of a single method: the price equals a reference price, plus or minus a margin. The resulting all-in price, the amount to be delivered and the amount to be received are stated in the Quote before the Client accepts it.

3.2 Reference price. The reference price is the executable market price of the relevant pair at the time of the Quote on the trading venue that BITX uses as its principal liquidity provider, cross-checked against the other venues BITX uses and, for fiat-currency and stablecoin pairs, against independent market-data sources. For a Purchase by the Client the reference is the offer (ask) side of the market and for a Sale the bid side. For transactions whose size is large relative to the available liquidity, the reference is the volume-weighted average price actually obtained by BITX when covering the transaction on its own account, so that the price reflects BITX's real cost or proceeds rather than an estimate. The reference price, its source and its timestamp are recorded for every transaction.

3.3 Margin. BITX applies a commercial margin over the reference price. The margin is set by BITX within limits that it reviews periodically and reflects objective factors: the liquidity and volatility of the crypto-asset; the size of the transaction and its expected impact on the market; the settlement currency, the network on which delivery takes place and the associated transaction costs; and the characteristics of the relationship with the Client, in particular the expected volume and frequency of its transactions and its risk profile. The margin applicable to a Client is confirmed when the business relationship is established, is applied consistently to that Client's transactions and is reflected in the price stated in every Quote. It is not renegotiated transaction by transaction.

3.4 Explicit fees. BITX's remuneration for the service is the margin. Where BITX applies any explicit fee to a transaction, that fee is stated separately in the Quote before acceptance. BITX does not charge any fee that is not stated in the Quote.

3.5 Quotes. A Quote states the all-in price, the amounts to be delivered and received, the margin and any explicit fee, the settlement instructions and its validity period, which is normally a few minutes. Once the validity period has expired a new Quote must be requested. BITX may withdraw a Quote before its acceptance in the event of market disruption, loss of liquidity or an operational incident.

3.6 Firm price. The conditions under which a price becomes firm depend on the direction of the transaction. In a Purchase (the Client delivers funds and receives crypto-assets), the Quote issued in response to the Trade Request is indicative; the Firm Price is issued once the Client's funds have been received and reconciled in BITX's safeguarding account, and the transaction is concluded when the Client accepts that Firm Price within its validity period. In a Sale (the Client delivers crypto-assets and receives funds), the Quote becomes a Firm Price upon the Client's acceptance within its validity period, because BITX covers its position on its own account at that moment. Once a Firm Price has been accepted, BITX bears the market risk until settlement and does not pass on any subsequent market movement to the Client.

3.7 No best execution. BITX acts as principal and does not owe the Client best execution. The price quoted by BITX may be higher or lower than prices available from other providers; Clients are free to compare them before accepting a Quote.

4. Costs and fees

4.1 The costs and fees associated with the service are the following:

4.2 Prices are stated exclusive of any taxes payable by the Client.

5. Limits on the amounts exchanged

5.1 BITX assigns each Client a transactional profile with limits when the business relationship is established, on the basis of the Client's declared activity, source of funds and expected volume. Transactions outside that profile require prior notice to BITX and may be subject to additional verification or declined.

5.2 BITX may decline, delay or suspend any transaction for the reasons set out in the Terms and Conditions, in particular where its compliance obligations so require.

6. Approval, review and amendments

6.1 This Policy has been approved by BITX's management body, which reviews it at least annually and whenever a change in law, in BITX's services or in market conditions so requires.

6.2 BITX may amend this Policy at any time by publishing the amended version on this website. The amended Policy applies to Quotes issued after its publication and does not affect Firm Prices already accepted. Previous versions are available on request at legal@bitx.es.